West Virginia Maintains May 28 LIHTC Application Deadline

The West Virginia Housing Development Fund (Fund) is currently committed to the due date of May 28, 2020, by 4:30 pm ET.

However, given this commitment and the COVID-19 outbreak, which could impact third party reports/signatures, the Fund wanted to poll our mailing list to determine if there are any other perceived roadblocks to submitting by the scheduled due date.

What we need:

  1. If you plan to submit an application, and have been notified by a third-party that they may not be able to provide the needed reports/signatures for your Reservation Request by the due date, please provide the following:
    1. The specific delayed report/signature and
    2. If known, what is the estimated date the report/signature will be delayed until?
  2. If you plan to submit an application and do not find any issues with fulfilling the May 28 deadline, please advise us of that fact.

We realize that no one knows how long the stay-at-home protocol will persist, or which states will be impacted the longest, but we wanted to let you know that we are interested in your thoughts regarding this topic.

We encourage you to continue working on your 2020 properties, as much as possible in case things start opening up and we are able to keep the stated due date.

Programmatic Deadlines

Upcoming (and possibly concerning) deadlines:

  • 2019 Selected Properties must fulfill the ten percent test and other time-sensitive Carryover Allocation Certificate Special Conditions within one year of the property’s Carryover Allocation Certificate and
  • 2018 Selected Properties must place in service by December 31, 2020.

We are aware and share your concern regarding the above listed deadlines.  We have been in contact with the National Council of State Housing Agencies along with most all other State Housing Financing Agencies in providing a united voice in seeking regulatory relief.

Unfortunately, the Fund cannot simply waive the ten percent test or lengthen the time by which it must be met.  Nor can the Fund extend the time period by which a property must place in service.  If the requested regulatory relief is not granted, the Fund will most likely explore other options for relief, such as an across-the-board administrative waiver for properties needing more time.  Any waiver would likely include the return of credit and re-allocation of credit to the impacted properties.

What we need:

If you currently have a 2018 property under construction or rehabilitation, it may be helpful for us to understand where you are in completing your property.  If you are finished–great–we would like to know that.  If you are not finished – what current roadblocks (if any) are you facing to complete your property?

Please send responses to Michele Wilshere, senior manager of the LIHTC program.